Plaintiff alleged executive directive violated religious obligation to confront systemic injustice; court found no legal basis under RFRA, First Amendment, or Section 1983
Brandon Jeanpierre, founder of a religious group called the Black Flag, sued former President Donald Trump earlier this year, claiming that Trump’s Executive Order 14253 interfered with his religious freedom. On November 18, 2025, U.S. Magistrate Judge Daphne A. Oberg dismissed the suit with prejudice, ruling that it failed to state a valid legal claim.
The lawsuit, filed in the U.S. District Court for the District of Utah under Jeanpierre v. Trump, No. 2:25-cv-00290, challenged an executive order titled “Restoring Truth and Sanity to American History,” issued March 27, 2025. The order directed federal agencies to remove “divisive race-centered ideology” from historical exhibits and to restore certain monuments altered after January 1, 2020. Jeanpierre argued that this government directive contradicted the spiritual tenets of his religion, which includes a religious mandate to recognize and dismantle systemic racism .
Jeanpierre brought claims under the Religious Freedom Restoration Act (RFRA), the First Amendment, Bivens v. Six Unknown Named Agents, 42 U.S.C. § 1983, and Article 18 of the Universal Declaration of Human Rights. He sought declaratory and injunctive relief, along with compensatory damages.
The court found no legal basis for the claims. Judge Oberg wrote that the executive order did not require Jeanpierre to change his religious practices or adopt the government’s historical view. “The order demands nothing from him,” the court stated. It imposed no penalties, compelled no speech, and made no contact with Jeanpierre directly. Because of this, his religious exercise had not been burdened under RFRA or the Free Exercise Clause .
The court also rejected Jeanpierre’s use of 42 U.S.C. § 1983. That statute provides a remedy when someone acting under color of state law violates a federally protected right. Judge Oberg explained that § 1983 does not apply to federal officials. Trump was acting in a federal capacity when issuing the executive order. Because of that, § 1983 could not apply.
Section 1983 is a procedural statute. It does not create any rights of its own. It is used to enforce existing constitutional or statutory rights. It is also limited to actions against state actors. Federal officials can be sued in limited cases through the Supreme Court precedent in Bivens, but that doctrine has never been extended to First Amendment claims, and it does not authorize the kind of relief Jeanpierre requested.
Jeanpierre was given an opportunity to amend his complaint after the court screened it under 28 U.S.C. § 1915. He failed to do so. The court concluded that any further effort to revise the complaint would be futile and ordered the case dismissed with prejudice .
Legal Commentary: Why Section 1983 Did Not Apply
Jeanpierre’s case shows a common mistake in federal litigation. Many plaintiffs rely on 42 U.S.C. § 1983 without understanding its limits. Section 1983 provides a civil remedy for violations of federal rights by state actors. It does not cover actions by federal officials, such as the President or members of Congress. That alone defeats the claim.
Even if Jeanpierre had sued a state actor, he still needed to show a violation of a specific constitutional right. The court found no such violation. The executive order changed the conduct of federal agencies. It did not affect Jeanpierre directly. He was free to believe, preach, and teach whatever he wanted. Courts require a real burden, such as forced action or denial of benefits, to establish a claim under RFRA or the Free Exercise Clause.
The court also rejected the claim under Bivens. This doctrine applies only to a narrow set of circumstances and has not been extended to First Amendment claims. The Supreme Court has become increasingly reluctant to allow lawsuits against federal officials under Bivens, especially when Congress has provided other avenues for relief, such as RFRA.
International declarations, like the Universal Declaration of Human Rights, may reflect broad principles, but they do not create enforceable legal rights in U.S. courts.
This case was handled under the in forma pauperis statute, which allows courts to screen and dismiss legally defective lawsuits before they proceed. The court followed that process here and allowed Jeanpierre to amend his complaint. He did not, and the result was final dismissal.
Read the full decision: https://cases.justia.com/federal/district-courts/utah/utdce/2:2025cv00290/155892/12/0.pdf?ts=1763571539
TLDR (Too Long / Didn’t Read Summary)
On November 18, 2025, a federal judge dismissed a lawsuit filed by Brandon Jeanpierre against Donald Trump over Executive Order 14253. Jeanpierre alleged that the order, which removed race-centered narratives from federal exhibits, violated his religious beliefs. The court found that the order imposed no burden on Jeanpierre and did not violate RFRA, the First Amendment, or any enforceable legal standard. The claim under Section 1983 failed because the law applies only to state officials. The case was dismissed with prejudice.
📬 Like this article?
Subscribe to ReligiousLiberty.TV to get breaking updates on religious freedom cases, court rulings, and legal analysis delivered directly to your inbox. Stay informed about the issues that affect liberty of conscience.
AI Disclaimer
This article was produced with the assistance of artificial intelligence.
Legal Disclaimer
This article is for informational purposes only. It does not constitute legal advice. Consult a licensed attorney for legal advice about your specific situation.
Tags:
Section 1983 lawsuit limitations, Trump Executive Order 14253, Jeanpierre v. Trump, RFRA religious freedom case, Free Exercise Clause litigation
Source: ReligiousLibertyTV on Substack
